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Interswitch Limited

Conflict of interest

Where a Director or employee of Interswitch fails to declare a conflict of interest when the company engages the services of a consultant/vendor, e.g. where an architect is engaged to design and build the company’s new office complex and that architect is a close relative of a director or employee.

Requests or directions to engage a vendor or use a third-party because of a “special relationship.”

Financial or other interests and positions in companies in which you could influence Interswitch’s current or future business with those companies, customers, consultants or suppliers.

Decisions where the potentially affected parties have close personal or family relationships with you, or where you or your family might stand to personally benefit.

Discounts, gifts, payments or other benefits from suppliers, customers or others who conduct or want to conduct business with Interswitch.

Recruiting, hiring, or directly supervising family members or promoting someone with whom you have such a relationship.

Carrying out external functions during Interswitch business hours or using Interswitch resources, intellectual property or confidential information for non-Interswitch related work.

Being an officer or director of a charitable or civic organization that may obtain (or seek to obtain) funding or support from Interswitch.

Sharing Interswitch business secrets without your manager’s approval, or in any manner that conflicts with a nondisclosure agreement, or beyond what is necessary to achieve the objectives of the project in which you may be collaborating with a competitor.

Serving on the board of a competitor.

Entering into exclusive arrangements or noncompetition agreements.

Entering technology license agreements that may restrict the freedom of the licensee or licensor.

Entering into joint bidding or supply arrangements, or forming a joint venture.

Dealing with government officials

Deviation from contract requirements when providing goods or services to a government or government-owned enterprise.

Providing information without conducting due diligence to verify that all such information is current, accurate and complete before signing and providing to a government official.

Deviating from a government’s public procurement or tender process.

Recruiting a government official or member of the official’s family for employment at Interswitch while the official is in a position to influence Interswitch’s business with the government.

Situations that could be dangerous; for example, a colleague spilling a drink by the doorway and not ensuring that the spill is cleaned up to avoid anyone slips.

Anyone who disregards our policies, legal requirements or otherwise acts in a way that places others at risk, such as a manager requesting anyone to work when not fit for duty.

Improper Payments

Requests by sales representatives or vendors – especially those who deal with government officials — for high commissions, reimbursement for excessive entertainment or unauthorized travel expenses, or commissions before an award.

Requests for payments to an individual, an offshore account, or to a legal entity or account holder other than what is specified in a contract.

Requests for travel, lodging or hospitality for government officials, customers or their family members or friends.

Requests for donations to charities or organizations that may be affiliated with a government official or a customer.

Any service provider that suggests unusually “fast” clearance of goods through customs, visas or work permits through immigration, or issuance of government permits.

Requests to record a transaction inaccurately or incompletely, or expedite approval or payment in a way that might compromise financial controls.

Payment requests for “vague” goods/services, or when the deliverables are uncertain or unclear.

Intellectual Property & Confidential Information breaches

Giving out licenses, rights or access to our intellectual property or other information without authorization, or accepting intellectual property or confidential information without appropriate approvals.

Using non-approved devices or tools, misusing approved devices/tools, or sharing your credentials, passwords, tools, or equipment ― all of which could lead to loss of intellectual property or damage to our IT systems.

Misuse of Interswitch intellectual property or confidential information or finding that others have reverse-engineered Interswitch products, processes, services or designs.

Failure to honor obligations under a non-disclosure agreement or invention assignment agreements.

Privacy

Storing, transferring or using personal data not required for a legitimate business purpose.

Leaving personal or customer data at a printer, on a shared server, or on a publically accessible computer or site.

Disclosing personal data to any unauthorized persons or organizations.

Financial transactions recorded with a misleading information, including false expenses, purchase orders, inaccurate time sheets or vouchers.

Transactions or financial statements that do not appear consistent with the actual business performance.

Any effort to avoid appropriate reviews for a transaction, or actions inconsistent with an employee’s level of authority.

Any absence of controls on transactions, such as dual signatures on checks or required approvals on expenses, particularly where cash is involved.

Retaliation occurring as a result of any whistleblowing report

Seeking revenge against someone who makes a report

Vendor / Third Party Misconduct

Being pressured to select a specific supplier – regardless of the outcome of the supplier selection process.

Suppliers offering anything of value (e.g. hiring your relative) to be selected, maintain or increase business, to overlook contract terms, audit or quality issues or to avoid any other requirements or lawful practices.

Suppliers that resist the standards contained in Interswitch Supplier Requirements, including ethical behavior, labour and human rights, health and safety and the environment.

Suppliers that do not address reasonable concerns, corrective actions or audit findings in a timely manner.

Suppliers that claim they can meet unrealistic delivery schedules or pricing, expedite customs issues or attempt to use Interswitch’s good name or logo in an unauthorized manner.

Suppliers that are owned or controlled by the government or a government official or close family member, or a supplier that claims it can exercise improper influence with the government or with a customer.

Other

All other conduct that is inconsistent with our Code of Conduct and Financial Crimes Policy